The assessment of A.Y. 2009-10 was sought to be reopened on the ground that license fee paid by the assessee for the use of a logo was capital in nature, whereas the assessee had claimed it as a revenue expenditure. This was done pursuant to the objection raised by the audit party. Assessee challenged such proceedings in writ. Quashing the notice and the subsequent order, the High Court noted that the AO had allowed such expenditure as being revenue in nature, in preceding as well as in succeeding years. In some of these years, queries regarding such payment were also raised. Thereafter, taking a contrary view based on audit objections alone amounts to change in opinion and the reassessment proceedings are therefore bad in law. (AY. 2009-10)